EXHIBIT 14
CODE OF CONDUCT
INTEGRITY IN
EVERYTHING WE DO...
IT STARTS WITH ME
OUR MISSION
Boston Scientific's mission is to improve the quality of patient care and the
productivity of health care delivery through the development and advocacy of
less-invasive medical devices and procedures. This is accomplished through the
continuing refinement of existing products and procedures and the investigation
and development of new technologies that can reduce risk, trauma, cost,
procedure time and the need for aftercare.
IT STARTS WITH ME
Dear Boston Scientific Team Members,
Personal and corporate integrity has been one of Boston Scientific's guiding
principles since the day our company was founded. It enters into everything we
do and is a central part of our daily lives.
All of us need to be comfortable talking about integrity openly and in detail.
This updated Code of Conduct is a cornerstone of our Corporate Integrity Program
as well as the basis for that conversation. As you read through our Code, we're
sure much of it will impress you as common sense. We believe that what is
written here is already second nature to you. However, as we grow and expand our
global operations in an increasingly regulated environment, it is more important
than ever that we have a single definition of corporate integrity and a common
understanding of what we expect of every member of the Boston Scientific team.
Our good reputation-and our company's future-depend on how we deal with others,
both inside and outside of Boston Scientific. Acting with fairness and honesty
in all of our actions is fundamental to how we do business. It extends far
beyond simple respect for the laws in all locations where we do business to
include how each one of us behaves in our daily interactions with others as we
do our jobs. Our Board of Directors has reviewed and embraces this Code. They,
and we, believe that achieving our business objectives should never demand that
we sacrifice either our personal integrity or the company's.
Our Code of Conduct will help you understand how to handle ambiguous situations.
The line between "right and wrong" is not always clear, and it can be difficult
to know how to proceed, especially in a highly regulated environment. Our Code
also provides guidance on how to express any integrity concerns you may have. If
you see something you believe is wrong that is not resolved properly through the
regular channels, you should know that you can bring it directly to one of us.
Just as integrity is part of who we are as individuals, it is also part of who
we are as members of the Boston Scientific team. Every one of us is responsible
for our company's integrity and reputation.
Our Code is designed to help each of us meet that responsibility and provides
the foundation for each of us to say, "there is integrity in everything we do
.... it starts with me."
Sincerely,
Pete Nicholas Jim Tobin
Chairman of the Board President and Chief Executive Officer
COMMITMENT AND ACCOUNTABILITY................................................................ 1
Policy Statement............................................................................. 1
Individual Responsibility.................................................................... 1
Manager Responsibility....................................................................... 2
Getting Advice and Reporting Integrity Concerns.............................................. 2
OUR BUSINESS RELATIONSHIPS................................................................... 2
Marketing, Advertising and Sales Practices................................................... 2
Use and Receipt of Gifts and Business Gratuities (Meals and Entertainment)................... 2
Our Relationships with other Businesses...................................................... 3
Governments and Our Respect for Local Laws and Customs....................................... 3
U.S. Health Care Programs and Government Contracts........................................... 3
Our Competitors.............................................................................. 4
Compliance with Antitrust, Fair Competition and Anti-Monopoly Laws........................... 4
Respect for Patents, Trade Secrets, Trademarks, Copyrights and Other Intellectual Property... 4
OUR WORK AND OUR WORK ENVIRONMENT............................................................ 5
Treating People with Respect, Courtesy, Fairness and Dignity................................. 5
Fair Employment Practices; Non-Harassing Environment......................................... 5
The Quality of Our Products, Work and Research............................................... 5
Duty of Loyalty; Conflict of Interest........................................................ 6
Environment, Health, Safety and Security..................................................... 7
Political Activities and Contributions....................................................... 7
COMPANY INFORMATION AND COMPANY PROPERTY..................................................... 7
Company Information; Protection of Ours and Proper Receipt of Others' Information............ 7
Publicly Traded Stock; Proper Disclosure of Material Nonpublic Information................... 8
Media/Public/Attorney Contacts............................................................... 9
Accuracy, Retention and Disposal of Records ................................................. 9
Financial Reporting and Records.............................................................. 10
Use of Company Property...................................................................... 10
CONDUCTING BUSINESS GLOBALLY................................................................. 11
Business with Governments and Government Officials........................................... 11
Import and Export Laws....................................................................... 11
Anti-boycott Laws............................................................................ 12
CORPORATE INTEGRITY PROGRAM ADMINISTRATION .................................................. 12
What is Our Corporate Integrity Program?..................................................... 12
Corporate Integrity Program.................................................................. 12
Advice Line.................................................................................. 13
Corporate Integrity Program Investigations................................................... 13
No Retaliation Policy........................................................................ 13
Code of Conduct Written Certifications....................................................... 13
Code of Conduct Waivers...................................................................... 14
Monitoring, Auditing, Corrective Action and Discipline ...................................... 14
CONCLUSION................................................................................... 14
INDEX........................................................................................ 15
AT&T DIRECT ACCESS CODES FOR BSC LOCATIONS .................................................. 17
CORPORATE INTEGRITY CHECKLIST FOR TEAM MEMBERS .............................................. 18
GETTING ADVICE AND REPORTING CONCERNS CHART.................................................. INSIDE BACK COVER
Thanks to Michael Rion for allowing us to adapt his copyrighted questions
included in the INDIVIDUAL RESPONSIBILITY section of this Code.
COMMITMENT AND ACCOUNTABILITY
POLICY STATEMENT
This Code of Conduct is a formal statement of our commitment, as a company and
as individuals, to conduct our business with integrity at all times. It
expresses our common understanding of what we at Boston Scientific mean when we
talk about acting with integrity. It means that:
- - We respect both the laws of all places where we operate and our own company
policies and procedures;
- - We are honest and treat people with respect, courtesy, fairness and dignity;
and
- - We work hard to make Boston Scientific a great place to work and a company
that is respected for the quality of its people and products.
This Code is the cornerstone of our Corporate Integrity Program. Each of us on
the worldwide Boston Scientific team is expected to comply with the spirit as
well as the letter of this Code in all of our dealings on Boston Scientific's
behalf. Since no code of conduct can anticipate every situation that we may
encounter, many of the concepts described in this Code are further explained in
our policies and procedures. The broad guidelines of this Code can help us make
appropriate decisions and act with integrity when facing challenging situations
in the course of performing our jobs.
For simplicity, "Boston Scientific" is used throughout this Code to identify the
global network of companies directly or indirectly owned by Boston Scientific
Corporation and "Boston Scientific team" refers to the members of Boston
Scientific's Board of Directors, all Boston Scientific employees and all other
workers providing services on Boston Scientific's behalf, and is not intended to
imply that these board members or other workers are Boston Scientific employees.
While workers who are not our employees owe a duty of loyalty to their employer,
not to Boston Scientific, they must abide by all of the other provisions of this
Code while providing services to or on behalf of Boston Scientific.
INDIVIDUAL RESPONSIBILITY
We all must be role models for corporate integrity. Every one of us can
influence and lead our fellow team members when it comes to behaving honorably.
Only by working together can we maintain our culture of unshakeable integrity
and accountability. This means acting with fairness and honesty in all of our
dealings and exercising sound judgment in performing our jobs. None of us needs
to face challenging situations alone, but should ask questions and seek
appropriate input from our managers before making decisions or taking actions
that might raise legal or ethical issues. We must never take any action that our
manager or the Legal Department has indicated would be inappropriate or would
violate laws or our policies. When confronted with new, unclear, or important
situations, we need to consider:
- - Should this bother me?
- - Who else does this affect?
- - What is my role and responsibility?
- - What are the integrity and legal concerns? Is the issue addressed in the Code
of Conduct?
- - Who should I ask for help?
- - Am I being true to myself? To Boston Scientific?
Each of us is responsible for having a basic understanding of issues covered by
this Code and of Corporate Integrity Program policies, as well as corporate,
regional, site, departmental or other policies and procedures that apply to our
job. If you are uncertain of which policies and procedures apply to your job,
check with your manager. Individual responsibilities are summarized on the
CORPORATE INTEGRITY CHECKLIST FOR TEAM MEMBERS included in the back of this
Code.
MANAGER RESPONSIBILITY
In addition to team member responsibilities, managers are responsible for
setting direction and maintaining an environment in your work groups that
supports and fosters corporate integrity. Managers are required to review this
Code and the CORPORATE INTEGRITY CHECKLIST FOR TEAM MEMBERS included in the back
of this Code with their direct reports at least annually.
GETTING ADVICE AND REPORTING INTEGRITY CONCERNS
When you are faced with concerns about legal and business integrity issues,
discuss the matter with your manager and immediately report any business conduct
that appears to be illegal or unethical or with which you are uncomfortable. If
reporting such conduct to your manager is difficult or seems inappropriate for
any reason, you have a number of alternatives. Consider discussing your concern
with your manager's manager or a member of your site, regional, or divisional
senior management. You may always call your Human Resources representative, a
Legal Department lawyer, or the toll-free Advice Line. Or it may also be helpful
to discuss concerns with a person who has management responsibility in the
appropriate functional area like Sales, Marketing, Regulatory Affairs, or
Operations. Other options are to contact an employee from Corporate Analysis and
Control or Corporate Security. These resources are summarized in the chart at
the back of this Code. For additional information, please read the ADVICE LINE,
CORPORATE INTEGRITY PROGRAM INVESTIGATIONS and NO RETALIATION POLICY sections of
this Code. If you raise an integrity concern and believe that it has not been
timely addressed, continue to raise it to an appropriate individual until it is
addressed.
OUR BUSINESS RELATIONSHIPS
MARKETING, ADVERTISING AND SALES PRACTICES
We believe that enduring customer relationships are based on integrity and
trust, and that our marketing, advertising and sales practices must be both
legal and ethical. We must work zealously, honestly and in good faith with our
hospital and physician partners on behalf of the millions of patients who
entrust themselves to that partnership. We must present product information that
is truthful, accurate, fully informative and fair. All sales and marketing
materials must be based on facts and documented research and include all
information required by regulatory agencies (such as the U.S. FDA, the Japanese
PMDA, or a European Competent Authority). All sales and marketing materials must
be pre-approved in accordance with our policies. We do not sacrifice integrity
to make or maintain sales. Our marketing and sales activities must not encourage
customers, or their representatives, to place their personal interests above
those of their employers or patients.
USE AND RECEIPT OF GIFTS AND BUSINESS GRATUITIES (MEALS AND ENTERTAINMENT)
Certain laws and Boston Scientific policy limit the giving and receiving of
gifts, payments and business gratuities. Giving or receiving gifts, meals, or
entertainment in our internal and external business relationships is prohibited
unless they meet all of the following criteria:
- - They do not violate applicable law or fail to respect generally accepted
ethical standards, including the standards of the recipient's employer,
professional association, or organization;
- - They have a valid business purpose;
- - They are appropriate as to time, place, value (modest; not lavish or
extravagant) and kind;
- - They are infrequent in occurrence; and
- - They do not influence or give the appearance of influencing the behavior of
the recipient.
Except as explicitly permitted in a local Boston Scientific policy, we do not
give or receive gifts of cash.
Remember that an employee of a public or government-owned hospital is a
government employee. We cannot provide any gifts, meals, entertainment, or other
business gratuity to a government employee, except as permitted by local law,
and then only with all prior approvals required by Boston Scientific policy.
OUR RELATIONSHIPS WITH OTHER BUSINESSES
When engaging third parties (suppliers, contractors, consultants and
distributors), remember:
- - Give third parties a chance to compete fairly for our
business.
- - Do not retain a third party to do anything illegal or improper. What we cannot
do directly, we cannot do indirectly by acting through another.
- - Consult your senior site, regional, or divisional management before engaging a
third party if a conflict of interest exists or may arise. For additional
information, please read the DUTY OF LOYALTY; CONFLICT OF INTEREST section of
this Code.
- - Choose only third parties who are genuinely qualified and have a good
reputation for quality and honesty.
- - Make sure all agreements with physicians and other health care providers are
documented in a writing that has been reviewed by the Legal Department.
Sometimes, if certain requirements are met, a standard form provided by the
Legal Department can be signed without modification. A copy of all signed
agreements must be provided to the Legal Department.
GOVERNMENTS AND OUR RESPECT FOR LOCAL LAWS AND CUSTOMS
Boston Scientific has many dealings with various governments and government
officials. It goes without saying that all such dealings must be conducted with
integrity and in an honest and forthright manner. We do not want to take any
action that could be viewed as an attempt to influence the decision-making
process of a government or its officials by improperly offering any benefit that
could be seen as a bribe or kickback. By the same token, requests or demands by
a government representative for any such benefit must be reported immediately to
the Legal Department.
We respect the letter and the spirit of the laws and customs of all locations
where we operate. Laws vary from place to place, and what may be legal in one
place may be illegal in another.
Occasionally, conduct that is legal or customary locally may violate our
policies. If you are concerned about a possible conflict between our policies
and any local laws or customs, contact the Legal Department or call the
toll-free Advice Line.
U.S. HEALTH CARE PROGRAMS AND GOVERNMENT CONTRACTS
Boston Scientific generally does not hire or retain people to work in our U.S.
operations who have been excluded, debarred, suspended, or are otherwise
ineligible to participate in U.S. government health care programs (like
Medicare, Medicaid, CHAMPUS) or other U.S. government procurement and
nonprocurement programs (each an "Ineligible Person"). On a periodic basis,
Boston Scientific searches applicable U.S. government databases to confirm that
Boston Scientific's U.S. employees are not listed in such databases as an
Ineligible Person. Any U.S. employee who becomes an Ineligible Person must
disclose immediately the details of such exclusion, debarment, suspension, or
other ineligibility to the Director of Corporate Integrity and Compliance
(508-650-8477).
OUR COMPETITORS
Boston Scientific is a vigorous competitor in the marketplace. While we seek
business-related information about our competitors, we do not do so in an
unfair, illegal, or improper manner. It is appropriate to obtain information
about competitors through legal and ethical means such as public documents,
public presentations, journal and magazine articles, and other published
information. No one should urge a competitor's former or current employees,
customers, or suppliers to disclose a competitor's confidential information. If
someone offers us another person's or company's information that we have no
right to know, we must decline it. If such information comes into our
possession, we will not use it improperly for our own competitive advantage. If
you receive such confidential information, immediately contact the Legal
Department, Corporate Security, or call the toll-free Advice Line. If we hire
someone who worked for a competitor, each of us (including the newly hired
employee) must respect that person's continuing legal and ethical obligations to
his or her former employer.
COMPLIANCE WITH ANTITRUST, FAIR COMPETITION AND ANTI-MONOPOLY LAWS
We win business because we develop, manufacture and sell excellent products,
provide valued education to our customers and act professionally. We have no
need or desire to win business through illegal or unethical conduct. We support
fair and vigorous competition on a level playing field. Antitrust, fair
competition and anti-monopoly laws and regulations help preserve fair
competition by limiting abusive behavior and we respect these rules.
In order to avoid creating even an appearance of illegal or unethical conduct
with respect to these laws and regulations, it is important not to discuss
sensitive topics with any person or company outside of Boston Scientific,
including competitors, suppliers, trade associations, or business-to-business
exchanges, without first obtaining advice from the Legal Department and entering
into appropriate confidentiality agreements. "Sensitive topics" include all
aspects of product pricing, the market(s) for our products, products under
development, marketing and sales plans and key costs, such as research and
development or labor costs, etc. If a competitor raises a sensitive topic, end
the conversation immediately and properly document your refusal to participate
in the conversation by notifying the Legal Department.
Each team member should deal fairly with our customers, suppliers, competitors
and other team members. This means that no team member should take unfair
advantage of anyone through manipulation, concealment, abuse of privileged
information, misrepresentation of material facts, or any other unfair business
practice.
RESPECT FOR PATENTS, TRADE SECRETS, TRADEMARKS, COPYRIGHTS AND OTHER
INTELLECTUAL PROPERTY
We vigorously develop, secure, maintain and protect our intellectual property
rights - patents, trade names, trademarks, copyrights and trade secrets. We also
respect the intellectual property rights of others and do not use them
improperly. We must not violate intellectual property licensing arrangements by
using the licensed property in an unauthorized manner, for example, unauthorized
copying of software or publications. Remember to mark products and corporate
publications (sales and marketing materials, presentations, or articles, for
example) with appropriate intellectual property notices. If you learn of another
person's or company's intellectual property that we may infringe, let the Legal
Department or Corporate Security know immediately. Likewise, immediately call
the Legal Department or Corporate Security if you learn of another person's or
company's activities that may infringe our intellectual property.
OUR WORK AND OUR WORK ENVIRONMENT
TREATING PEOPLE WITH RESPECT, COURTESY, FAIRNESS AND DIGNITY
A fundamental part of how we operate includes treating each other and our
customers with respect, courtesy and fairness. Being considerate of and
recognizing the dignity of all people is central to how we define ourselves. How
we act on this belief extends from respecting the confidentiality and privacy of
patient and personal information to handling customer requests and patient
inquiries promptly and courteously.
It also extends to acting professionally in any job-related activity, including
Boston Scientific-sponsored off-site events and social gatherings. We all know
and honor the fact that it is unacceptable to steal or damage the property of
customers, co-workers, or the company. Similarly, we do not create safety or
health hazards, verbally or physically mistreat others, or engage in offensive
behavior. This is a broad-ranging statement that includes far more than open
violence, fighting, or disorderly conduct. It encompasses harassing, abusive, or
intimidating treatment of any kind and the use of language or gestures that are
inappropriate, harassing, or abusive in nature. It also includes interfering
with a co-worker's job performance, using illegal drugs, or misusing or abusing
alcohol or prescription drugs. All of us, as members of the Boston Scientific
team, are expected to abide by all applicable policies regarding employee
conduct.
FAIR EMPLOYMENT PRACTICES; NON-HARASSING ENVIRONMENT
We are committed to following fair employment practices that provide equal
opportunities to all employees. We do not discriminate against or harass another
person on the basis of his or her race, color, religion, disability, gender,
national origin, sexual orientation, age, or other legally protected status.
This applies to all business and employment-related activities.
THE QUALITY OF OUR PRODUCTS, WORK AND RESEARCH
By performing our jobs with integrity, each of us helps to ensure that every
single medical device that we develop, manufacture, test and deliver meets
applicable government regulatory standards, our own stringent quality
requirements and, ultimately, patient needs. We all share the responsibility for
upholding Boston Scientific's standards and ensuring that our regulatory,
clinical and other quality system policies and procedures are followed
absolutely. Any complaint about a Boston Scientific product needs to be handled
in complete accordance with our policies and procedures. We must also do our
part to ensure that all clinical research conducted on behalf of Boston
Scientific is undertaken with rigor, meets applicable laws, privacy requirements
and government regulatory standards, and complies with other applicable
approvals or accords like Institutional Review Board/Ethics Committee/Privacy
Board approvals or the Helsinki Accord.
Quality is not limited to product quality. We must take pride in our work, and
pay careful attention to detail. Remember that everything we do reflects on
Boston Scientific. Quality does not just happen; it is the result of
conscientious effort by each and every one of us.
DUTY OF LOYALTY; CONFLICT OF INTEREST
All Boston Scientific employees, as well the members of our Board of Directors,
owe a duty of loyalty to Boston Scientific. In general, this means that we must
put our best efforts toward Boston Scientific's continued success and not take
for personal gain any commercial opportunities discovered through the use of
company property, information or our positions within Boston Scientific. In
addition, no employee or member of our Board of Directors, or any other team
member who has so agreed, should compete with Boston Scientific.
We must all do our best to prevent conflicts of interest, and to minimize any
appearance of conflicts of interest, with our job responsibilities. A conflict
of interest occurs when an individual's private interest interferes in any
significant way with the interests of Boston Scientific as a whole. Whether a
conflict of interest exists must be determined based on the facts and other
relevant information.
During our scheduled work hours, we must use our best efforts to perform our
jobs well. We are free to participate in outside activities, but it is important
not to engage in any activity that is (or could appear to be) a conflict between
our personal interests and Boston Scientific's best interests. We each have the
responsibility to make sure that our outside activities do not involve the use
of Boston Scientific's reputation. Examples of actual or potential conflicts of
interest include:
- - Situations where you, or a member of your family, could receive improper
personal benefit(s) as a result of your Boston Scientific position. This could
include giving Boston Scientific business to another company because a family
member or friend works at that company.
- - Outside activities or ownership interests that could influence your on-the-job
ability to make objective decisions that are in Boston Scientific's best
interests.
- - Hiring or having a reporting relationship with a relative.
- - Boston Scientific making loans to, or guarantees of obligations of a member of
the Board of Directors, the Executive Committee, or a senior financial officer.
- - Holding a second job or having a consulting relationship with a competitor or
a supplier.
We must disclose in advance all relevant facts about all possible conflicts of
interest. All determinations relating to such disclosures must be reviewed and
approved by a Vice President
or higher. The reviewing manager is responsible for obtaining guidance from the
Director of Corporate Integrity and Compliance, a Legal Department Attorney or
Human Resources, and for determining whether a conflict of interest exists and,
if so, how best to deal with it. In certain instances, appropriate safeguards
may be required to assure that a proposed activity is fair to Boston Scientific.
Examples of safeguards include having disinterested employees negotiate an
arrangement at arms' length and handle all aspects of any ongoing relationship.
Please see also the CODE OF CONDUCT WAIVERS section of this Code.
ENVIRONMENT, HEALTH, SAFETY AND SECURITY
We believe that sound environmental, health and safety performance contributes
to our competitive strength and benefits our customers, shareholders and team
members. All of us are responsible for helping to maintain a safe and healthy
workplace, respecting the environment and striving to conserve natural resources
in operating our business. Translated into day-to-day activities, that means
respecting all applicable environmental, health and safety permits and
regulations, reporting unsafe working conditions to our managers, using
resources efficiently, recycling when feasible, handling any
hazardous/biohazardous materials properly and disposing of all waste according
to applicable laws and our policies. Maintaining a secure workplace safeguards
our people, information and property. That is why we have access control systems
for our facilities and information systems and why it is important to follow
applicable security procedures.
POLITICAL ACTIVITIES AND CONTRIBUTIONS
All of us are free to participate as individuals in the political process, but
in doing so, we cannot create the impression of speaking or acting on Boston
Scientific's behalf. It is up to each of us to abide by all laws relating to
political contributions, and to make such contributions as individuals, not as
Boston Scientific representatives. We cannot contribute any Boston Scientific
money, property, time, or services (directly or indirectly) to any political
candidate or political party, unless making such a contribution is permitted by
local law, is made through specifically designated political entities and we
have the prior consent of senior Boston Scientific management (Senior Vice
President level or higher).
There may be instances where our collective experience may be helpful. In those
cases, Boston Scientific, through its senior site, regional, or divisional
management or specifically designated political entities, may publicly offer
recommendations about laws or governmental actions and take public positions on
issues that affect our business or impact health care.
COMPANY INFORMATION AND COMPANY PROPERTY
COMPANY INFORMATION; PROTECTION OF OURS AND PROPER RECEIPT OF OTHERS'
INFORMATION
Boston Scientific's company information is a very valuable asset. It encompasses
all proprietary information that is not generally available to or known by the
public, and it includes information in any format: written, electronic, visual,
or verbal. It also may include information that we develop, purchase, or
license, and information we receive from others (including suppliers and
customers).
Of course, each of us must maintain the confidentiality of all company
information entrusted to us, except when disclosure is authorized or legally
required. While we may use company information to the extent needed to perform
our jobs properly, we need to remember that we are responsible for safeguarding
that information (and information provided to Boston Scientific by another
person or company) from theft or misuse. Accordingly, we cannot, directly or
indirectly:
- - Disclose any company information to others, including other team members,
unless they have a legitimate need to know it to perform their jobs and, if they
are not Boston Scientific employees, have agreed in writing to maintain its
confidentiality;
- - Use company information for any purpose other than its intended use;
- - Copy any documents containing company information, or remove any documents or
other records or copies from our work area, except as required for us to perform
our jobs properly; or
- - Dispose of company information inappropriately.
All company documents, e-mail and other materials containing company information
relating to Boston Scientific (and all materials prepared from those documents)
are Boston Scientific's property. If the company requests, or when our
employment or other working relationship ends, these documents must be returned
to the company.
Many of us regularly disclose company information to others and/or receive
information from others for legitimate business reasons. Before disclosing or
receiving such information, we must enter into an agreement that describes how
the parties can use and must protect the information. Each agreement must be
pre-approved by the Legal Department; sometimes, if certain requirements are
met, a standard form provided by the Legal Department can be signed without
modification; in any case, a copy of all signed agreements must be provided to
the Legal Department.
It is also important to contact the Legal Department before presenting or
publishing any research results; that way, we can confirm that all appropriate
confidentiality agreements have been signed and any patent filings necessary to
protect our interests in the information have been made. Contact the Legal
Department as well if you learn of an outside person who plans to present or
publish research that may contain confidential company information or affect our
intellectual property rights. These obligations continue even after your
employment terminates.
PUBLICLY TRADED STOCK; PROPER DISCLOSURE OF MATERIAL NONPUBLIC INFORMATION
We are free to buy and sell Boston Scientific stock, as long as we do not engage
in "insider trading." Insider trading means buying or selling a company's stock
when we possess material nonpublic information. "Material nonpublic
information," generally speaking, is any information that a reasonable investor
might use to decide whether to buy, sell, or hold a company's securities.
Insider trading is a serious violation of the securities laws that can result in
substantial civil and criminal penalties.
Material information becomes "public" when it has been appropriately disclosed
to the public, usually through a company's press releases, public filings with
the Securities and Exchange Commission or has been widely reported in the media.
Only the Chief Executive Officer, Chief
Financial Officer, General Counsel and members of the Disclosure Committee have
the authority to determine when information should be released. Thus, we must
wait until Boston Scientific has publicly disseminated any material information
of which we have knowledge before we can make trades in Boston Scientific's
stock or discuss this information with third parties.
Furthermore, none of us may give "tips" to anyone, whether inside or outside of
the company, to enable him or her to buy or sell Boston Scientific stock based
on material nonpublic information gained through our relationship with Boston
Scientific. Trading based on a "tip" can result in civil and criminal liability
to both the person trading on the tip and the person making the tip. In general,
it is not wise to make any recommendations of any kind to any person about
buying or selling Boston Scientific stock.
We always need to be very careful when discussing information that could
influence someone else to buy, sell, or hold Boston Scientific stock. To protect
yourself, assume that all company information is material and confidential
unless you have seen Boston Scientific's authorized written public disclosure of
that information.
Many people do not realize that insider trading prohibitions also extend to
stock of our competitors and other businesses. Accordingly, we should not buy or
sell stock in another company about which we have material nonpublic
information. Investment in a company that is one of Boston Scientific's
competitors, vendors, or customers also requires prior approval, unless the
investment is in a publicly traded company and makes up less than one percent of
the company's total outstanding stock.
For those who have regular access to material nonpublic information, trading in
Boston Scientific stock may also give the appearance of impropriety.
Accordingly, the General Counsel or Chief Financial Officer may prohibit certain
individuals from trading in Boston Scientific stock when the existence of
material information is not public or where the risk of the appearance of
impropriety is high.
Please contact the Legal Department with any questions about stock trading.
MEDIA/PUBLIC/ATTORNEY CONTACTS
Press releases and contact with news media, securities analysts, or investment
bankers must be made only through or at the direction of the Chief Executive
Officer, Chief Financial Officer, or Vice President-Corporate Communications.
- - If a reporter or other member of the news media contacts you, refer him or her
to the Vice President-Corporate Communications immediately. If an analyst,
rating agency or investment banker contacts you, refer him or her to the Vice
President, Treasurer and Investor Relations. Never comment on, confirm, or deny
anything relating to company business, including rumors.
- - If an attorney, whether representing a person, another company, or the
government, contacts you regarding company business, refer him or her to the
Legal Department.
- - If you receive a summons, legal complaint, subpoena, or other similar legal
document, immediately consult with the Legal Department lawyer who represents
your area. You can also call the toll-free Advice Line.
ACCURACY, RETENTION AND DISPOSAL OF RECORDS
Each of us is responsible for maintaining accurate and reasonably detailed
documents, reports and other records. No one may falsify or improperly alter any
information contained in Boston Scientific records.
Good business practice requires that we retain certain Boston Scientific records
for various time periods. Often, these are required by law, and it's up to us to
see that they are retained in compliance with applicable document retention
policies. Documents that need not be kept should be disposed of in compliance
with company policies. Where litigation or a government investigation is likely
or ongoing, records may not be destroyed until the Legal Department advises that
the matter has been concluded.
For questions about document retention, contact the Vice President of Corporate
Analysis and Control, the toll-free Advice Line, or the Legal Department,
particularly if any litigation, investigation, or administrative action is (or
may be) pending.
FINANCIAL REPORTING AND RECORDS
In addition to the general guidelines described in the ACCURACY, RETENTION AND
DISPOSAL OF RECORDS section of this Code, all books, financial records, reports
and documents filed with or submitted to the Securities and Exchange Commission
and in other public communications and tax records must disclose fully, fairly,
accurately, timely and understandably the nature of Boston Scientific's
transactions and account accurately for Boston Scientific's assets and
liabilities. All transactions must be recorded in accordance with generally
accepted accounting principles and the rules and regulations of the Securities
and Exchange Commission. All revenue must be recognized only when it is realized
or realizable, earned, and collectibility is reasonably assured. No undisclosed
or unrecorded fund may be established for any purpose. Any off-balance sheet
transactions, arrangements, obligations (including contingent obligations), and
other relationships with unconsolidated entities or other person that may have a
material current or future effect on financial condition, changes in financial
condition, results of operations, liquidity, capital expenditures, capital
resources, or significant components of revenues or expenses must be disclosed
in required securities filings. False entries must never be made and permanent
entries must never be altered. An adequate system of internal accounting
controls must be maintained. Each team member is responsible for providing full
and accurate information to Corporate Analysis and Control and external auditors
engaged by the company. For questions about revenue recognition and other
financial reporting and records matters, contact the Corporate Controller.
Payments for goods and services provided to Boston Scientific must be payable to
the person or company legally entitled to receive payment. All invoices must
accurately reflect the items and services being purchased or sold and the prices
being paid. Generally, discounts must be included in the price or otherwise
stated on the invoice. If the discount is not known at the time of the sale,
then we must provide specific information about the discount to the customer on
a periodic basis that respects applicable laws. For example, U.S. law requires
that such information be provided on at least an annual basis. Except in rare
instances, no payment may be made to a party in a country other than the one in
which the party resides, maintains a place of business, or has delivered the
goods or provided the services for which payment is made.
USE OF COMPANY PROPERTY
When we use company property, it must be for legitimate business purposes and
for Boston Scientific's benefit. It is also our responsibility to protect that
property from theft, carelessness and waste and to use company property
efficiently. Company property may not be used for the personal gain of team
members or others. None of us may transfer any company property to other
persons, except in the ordinary course of business with appropriate authority.
Company property includes far more than many people realize. In addition to
physical plants, equipment, computers, software, inventory, corporate funds and
office supplies, company property includes our technologies, concepts,
intellectual property, product development strategies and projects, business
strategies and plans, customer lists, personnel data, marketing and sales plans,
company phone books, organization charts, product cost data, product pricing,
financial data and all other proprietary information about our business,
customers and team members.
All of Boston Scientific's information systems, including computers,
communications systems, magnetic media, e-mail, voice mail, and Intranet, Sales
Source and Internet access systems, are Boston Scientific's property and
generally must be used only for business activities. Incidental personal use is
permissible as long as it does not consume more than a trivial amount of
resources, does not interfere with productivity, does not preempt any business
activity, is otherwise appropriate and reasonable and is consistent with our
corporate values. Boston Scientific reserves the right periodically to access,
read, monitor, inspect and disclose the contents of, postings to and downloads
from all of Boston Scientific's information systems to the full extent permitted
by applicable law.
No one may use Boston Scientific's information systems at work to access, view,
post, store, transmit, download, or distribute any profane, obscene, derogatory,
harassing, offensive, or inappropriate materials. Additionally, none of us may
use these systems to send company information or copyrighted documents that are
not authorized for transmittal or reproduction.
CONDUCTING BUSINESS GLOBALLY
BUSINESS WITH GOVERNMENTS AND GOVERNMENT OFFICIALS
All countries around the world have laws that prohibit us from making or paying,
or offering to make or pay, money, gifts or inducements to influence government
officials, or to induce the purchase of our products or services. "Government
official" includes candidates for political office, political parties and
employees of public hospitals and international organizations, such as the
American Red Cross. "Inducements" are broadly defined to include anything of
value. Even if it were not illegal, we do not want to obtain or retain business
by giving gifts to officials of a government or a multinational organization
like the United Nations or the World Health Organization either to influence any
of their official acts, or to induce them to use their influence to affect any
governmental act. Also, we cannot give or offer a gift to any person or firm
where we know or have reason to believe that the gift will be passed on to a
government official for such purposes. Remember that physicians and health care
providers in many countries who are employed in the public sector are government
employees. For additional information, please read the USE AND RECEIPT OF GIFTS
AND BUSINESS GRATUITIES (MEALS AND ENTERTAINMENT) section of this Code.
IMPORT AND EXPORT LAWS
Team members involved in importing or exporting our products, technology, or
personal information need to be familiar with, and abide by, our policies and
procedures affecting imports and exports. We must obtain all required licenses
and accurately declare all goods we ship or transport in customs and shipping
documentation.
Many countries in which we operate have laws controlling the import and export
of technology, personal information and medical devices. Violations of import
and export control laws can occur if items exported to one country are
re-exported to another country subject to different import or export controls.
Violations can also occur merely by doing business with certain persons or
businesses affiliated with, owned by, or controlled by persons designated as
"prohibited entities."
The U.S. and other governments periodically impose trade restrictions, for
example, embargoes, on certain countries. These laws are complex and change
frequently. Customer service representatives at each distribution center can
answer questions about countries currently subject to trade restrictions.
ANTI-BOYCOTT LAWS
U.S. anti-boycott laws and regulations prohibit Boston Scientific from
participating in a boycott by one country of another country. While these laws
were passed primarily to address the Arab boycott of Israel, they are not
limited to that boycott.
All requests for Boston Scientific to cooperate in a boycott or to provide
information about our business with countries subject to a boycott must be
reported immediately to the Legal Department, and we must not respond to any
such requests for information. We are required by law to report promptly such
requests to the U.S. government.
CORPORATE INTEGRITY PROGRAM ADMINISTRATION
WHAT IS OUR CORPORATE INTEGRITY PROGRAM?
The Corporate Integrity Program was established to reaffirm our commitment to
conducting business with integrity at all times. Ethical issues can arise, even
when good people with the best of intentions are involved. Knowing just what to
do can be difficult. Our Corporate Integrity Program is intended to clarify our
corporate values, reinforce our commitment to acting with integrity in
everything we do, and provide guidance in dealing with ethical and legal
concerns.
Our Corporate Integrity Program includes this Code and our policies relating to
the laws that affect our operations. It also develops training on this Code and
those policies, and systems for monitoring compliance and addressing any
instances of non-compliance. Program materials are available at the Corporate
Integrity Program Intranet site (http://nat1wprd2/corp_integrity/) or from the
Director of Corporate Integrity and Compliance (508-650-8477).
The Audit Committee of the Board of Directors oversees the operation of the
Corporate Integrity Program. Other persons with responsibility for the Program
include the Senior Vice President,
General Counsel and Secretary, who serves as our Chief Corporate Integrity and
Compliance Officer, plus the Director of Corporate Integrity and Compliance, who
is responsible for the day-to-day operation of the Corporate Integrity Program.
A current list of the people serving in these roles is located on the Corporate
Integrity Program Intranet site (http://nat1wprd2/corp_integrity/).
CORPORATE INTEGRITY PROGRAM TRAINING
This Corporate Integrity Program and our Code of Conduct apply to each and every
one of us. Accordingly, all Boston Scientific team members must complete
required Corporate Integrity Program training. Refresher training modules and
training on policies relating to specific laws and/or jobs also will be made
available from time to time. All required training must be completed within the
applicable time frame. Any team member interested in obtaining additional
integrity training, either for themselves or for their direct reports, may call
the toll-free Advice Line (888-968-8425) or the Director of Corporate Integrity
and Compliance (508-650-8477).
ADVICE LINE
The Corporate Integrity Program maintains an Advice Line. The Advice Line is a
toll-free telephone number that anyone can call, 24 hours per day, seven days
per week, to ask for guidance about and to report integrity concerns. The
toll-free number is: 888-968-8425.
If you are calling from the U.S., Puerto Rico or Canada, you must dial
1-888-968-8425. If you are calling from anywhere else, you must first access
AT&T Direct by dialing the country-specific access code of the country from
which you are calling. The AT&T Direct access codes are printed in the back of
this Code and in advertisements in certain internationally distributed
newspapers. Once you reach AT&T Direct, dial 888-968-8425. Do not dial "1" or
"0" before dialing 888-968-8425 or you will be asked to provide billing
information. Certain international phone configurations require callers to press
the "*" key before dialing 888-968-8425. If you have trouble accessing AT&T
Direct, please confirm that the phone you are calling from is capable of placing
international calls.
The Advice Line may also be used to report anonymously (without giving your
name) possible illegal or unethical conduct. You need to be aware that if you
choose not to give your name, we may be less able to obtain necessary details to
follow up on a report, or to provide you, as appropriate, with possible
solutions to your concern, information relating to the resolution of your
concern, and/or the outcome of any investigation.
Calls to the Advice Line cannot be traced. The identity of the caller, and the
fact that the call to the Advice Line or other report was made, will be kept
confidential to the extent possible while still allowing a responsive
investigation to proceed.
CORPORATE INTEGRITY PROGRAM INVESTIGATIONS
Every concern and/or inquiry and every allegation of wrongdoing made through the
Corporate Integrity Program, including calls to the Advice Line, will be
reviewed, evaluated and responded to in a timely and impartial manner that
respects the rights of all parties concerned. Follow-up steps will include any
necessary corrective action or changes. Investigations will be confidential
to the extent possible in the circumstances. All of us must fully cooperate with
investigation efforts.
NO RETALIATION POLICY
Boston Scientific will not tolerate any form of retaliation against an
individual because he or she made a good-faith report, or assisted with or
cooperated in an investigation of a report, including reports made to or
investigated by Boston Scientific, a government or a government official. Boston
Scientific will also not tolerate any other form of retaliation that is
prohibited by applicable law.
CODE OF CONDUCT WRITTEN CERTIFICATIONS
You must certify that you have received a copy of this Code and understand that
abiding by the Code is a mandatory part of being a member of the Boston
Scientific team. It is not voluntary. Similar certifications will be required
after completing any required corporate integrity training.
In addition, each salaried employee and certain other employees in sensitive
jobs will be required to certify periodically that he or she has reported all
suspected or known violations of this Code.
CODE OF CONDUCT WAIVERS
Any waiver of this Code involving a member of the Board of Directors, the
Executive Committee or a Senior Financial Officer (Treasurer, Corporate
Controller), may be made only by the Board or a Board committee comprised of
disinterested Directors and must be promptly disclosed to shareholders as
required by applicable laws and regulations.
MONITORING, AUDITING, CORRECTIVE ACTION AND DISCIPLINE
As members of the Boston Scientific team, we are responsible for cooperating
with all Corporate Integrity Program monitoring and auditing activities. Any
violation of this Code or Corporate Integrity Program policies will be taken
very seriously. When a violation is identified, prompt and appropriate
corrective action will be taken to respond to the violation. This may include
making appropriate notifications and implementing changes to prevent further
similar violations. Failure to comply with the spirit as well as the letter of
this Code, and failure to participate in required training and Corporate
Integrity Program-related activities including monitoring and auditing
activities and investigations, will be considered in employment-related
decisions. It also may result in corrective or disciplinary action, up to and
including termination from employment. The corrective or disciplinary action
taken will vary based on the nature, severity and frequency of the violation.
CONCLUSION
Due to the complexity of our business and the competitive realities of the
marketplace, we must be clear about our corporate values and maintain a vigorous
commitment to acting with integrity. We must work zealously, honestly and in
good faith with our hospital and physician partners on behalf of the millions of
patients who entrust themselves to that partnership. We have a noble cause and a
noble calling. Let's keep it that way.
APPROVED BY THE BOARD OF DIRECTORS: FEBRUARY 24, 2004
A
accountability ....................... 1
accurate(ly).......................... 2, 9, 10, 11
analyst .............................. 9
anonymously .......................... 13
anti-monopoly ........................ 4
antitrust ............................ 4
appearance of impropriety ............ 9
appropriate/
inappropriate ........................ 1, 2, 4, 5, 6, 8, 10, 11, 13, 14, 18
ask questions ........................ 1, 13
B
boycott .............................. 12
bribe or kickback .................... 3
business gratuity(ies) ............... 2, 3, 11
C
certify/certification(s) ............. 13
challenging situations ............... 1
company information .................. 4, 7, 8, 9, 11
company property ..................... 6, 7, 8, 10
compete, competition, competitor(s)... 3, 4, 6, 7
comply/respect ....................... 1, 2, 3, 4, 5, 7, 10, 13
confidential ......................... 4, 5, 7, 8, 9, 13
conflict(s) of interest .............. 3, 6
cooperate ............................ 12, 13, 14, 18
copyright ............................ 4, 11
corrective action .................... 13, 14
courtesy ............................. 1, 5
co-workers ........................... 5
culture .............................. 1
customer(s)/
health care providers ................ 2, 3, 4, 5, 7, 9, 10, 11
customs .............................. 3, 11
D
dignity .............................. 1, 5
disclose/disclosure .................. 3, 4, 6, 7, 8, 9, 10, 11, 14
discount(s) .......................... 10
discriminate ......................... 5
document/ document retention ......... 3, 4, 8, 9, 10, 11
duty of loyalty ...................... 1, 3, 6
E
environmental ........................ 2, 5, 7
ethical/unethical .................... 1, 2, 4, 12, 13, 18
export(s) ............................ 11
F
fair/fairness/unfair .............. 1, 2, 3, 4, 5, 6, 10
false/falsify ..................... 9, 10
G
gift(s) ........................... 2, 3, 11
good faith ........................ 2, 14
government(s) ..................... 3, 5, 7, 9, 11, 12, 13
H
harass(ing) ....................... 5, 11
health care providers/
customer(s) ....................... 2, 3, 4, 5, 7, 9, 10, 11
honest/honesty .................... 1, 2, 3, 14
hospital .......................... 2, 3, 11, 14
I
illegal/legal ..................... 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13
import(s) ......................... 11
improper/proper ................... 3, 4, 6, 7, 8, 9
inappropriate/
appropriate ....................... 1, 2, 4, 5, 6, 8, 10, 11, 13, 14
individual responsibility(ies) .... 1
induce/inducements ................ 11
influence ......................... 1, 2, 3, 6, 9, 11
infringe .......................... 4
insider trading ................... 8, 9
integrity/integrity concern ....... 1, 2, 3, 5, 6, 12, 13, 14, 18
investigation(s) .................. 2, 9, 13, 14
invoice(s) ........................ 10
L
law(s) ............................ 1, 2, 3, 4, 5, 7, 8, 9, 11, 12, 13, 14
legal/illegal ..................... 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13
litigation ........................ 9
M
manager(s)(ment) .................. 1, 2, 3, 6, 7, 18
meals ............................. 2, 3, 11
mistreat .......................... 9
monitor ........................... 18
N
news media ........................ 9
non-compliance .................... 12
O
offensive ......................... 5, 11
outside ........................... 4, 6, 8
P
patent(s) ......................... 4, 8
patient(s) ........................ 2, 5, 14
payment(s) ........................ 2, 10
physician(s) ...................... 2, 3, 11, 14
policy(ies) ....................... 1, 2, 3, 5, 7, 9, 11, 12, 13, 14, 18
political ......................... 7, 11
privacy ........................... 5
product(s) ........................ 1, 2, 4, 5, 10, 11
proper/improper ................... 3, 4, 6, 7, 8, 9
proprietary ....................... 12, 16
Q
quality ........................... 1, 3, 5
R
records/documents ................. 3, 4, 8, 9, 10, 11
report(s)(ed)(ing) ................ 2, 3, 6, 7, 8, 9, 10, 12, 13, 18
research .......................... 2, 4, 5, 8
respect/comply .................... 1, 2, 3, 4, 5, 7, 10, 13
responsible/
responsibility(ies) ............... 1, 2, 5, 6, 7, 8, 9, 12, 13
retaliation ....................... 2, 13, 18
revenue ........................... 10
S
safe/safety/safeguard ............. 5, 6, 7
sensitive topics .................. 8
shareholders ...................... 7, 14
stock ............................. 8, 9
subpoena .......................... 9
supplier(s) ....................... 3, 4, 6, 7
T
third party(ies) .................. 3, 8
trade names ....................... 4
trade restrictions ................ 11
trade secrets ..................... 4
trademarks ........................ 4
training .......................... 12, 13, 14
trust ............................. 2
U
unethical/ethical ................. 1, 2, 4, 12, 13, 18
unfair/fair/fairness .............. 1, 2, 3, 4, 5, 6, 10
V
violate/violation ................. 2, 3, 4, 8, 11, 13, 14, 18
W
waiver ............................ 6, 14
AT&T DIRECT ACCESS CODES FOR BSC LOCATIONS
NOTE: These codes are current as of May 2004. An updated list is available by
calling the Director of Corporate
Integrity and Compliance at 508-650-8477 (collect or with charges reversed), or
visiting AT&T's web site at
http://www.business.att.com/.
Argentina 0-800-288-5288 (ALA)
0-800-555-4288 (Telecom)
0-800-222-1288 (Telefonica)
Australia 1-800-551-155 (Optus)
1-800-881-011 (Telstra)
Austria 0-800-200-288
Barbados 1-800-872-2881
Belgium 0-800-100-10
Brazil 0800 890 0288 or 0800-8888-288
Chile 800-225-288 (AT&T Node)
China, P.R. 108-888 (Netcom Group) (Northern
region, Beijing and vicinity)
108-11 (Telecom) (Southern region,
Shanghai and vicinity)
Colombia 01-800-911-0010
Czech Republic 00-800-222-55288 or 00-42-000-101
Denmark 8001-0010
Finland 0-8001-10015
France 0800-99-0011 or 0805-701-288
Germany 0800-2255-288
Greece 00-800-1311
Hong Kong 800-96-1111 (Hong Kong Telephone)
800-93-2266 (New World Telephone)
Hungary 06-800-01111
India 000-117
Ireland 1-800-550-000
Israel 1-800-94-94-949 (Bezeq)
Italy 800-172-444
Japan 00-539-111 (KDDI)
00-665-5111 (IDC)
00-441-1111 (JT)
Korea 0072-911 (Korea telecom)
0030 911 (DACOM)
Lebanon 426-801 (within Beirut)
01-426-801 (outside of Beirut)
Malaysia 1-800-80-0011
Mexico 01-800-288-2872
The Netherlands 0800-022-9111
New Zealand 000-911
Norway 800-190-11
Philippines 105-11 (Digitel) (Globe) (Philcom)
(PLDT) (Smart)
Poland 0-0800-111-1111
Portugal 800-800-128
Singapore 800-0111-111 (Sing Tel)
80-0001-0001 (StarHub)
South Africa 0-800-99-0123
Spain 900-99-00-11
Sweden 020-799-111
Switzerland 0800-89-0011
Taiwan 0080-10288-0
Thailand 1-800-0001-33 or 001-999-111-11
Turkey 00-800-12277
United Kingdom 0800-89-0011 (BT)
0500-89-0011 (C&W)
Uruguay 000-410
Venezuela 0-800-2255-288
CORPORATE INTEGRITY CHECKLIST FOR TEAM MEMBERS
Each employee, as well as all other non-employee team members who are regularly
at a Boston Scientific site, must act with integrity while conducting Boston
Scientific business. This includes following these basic obligations:
- - LEAD BY EXAMPLE, using your own behavior as a model for all other team
members.
- - ABIDE BY THE LETTER AND SPIRIT of our Code of Conduct and other
applicable policies.
- - HAVE A BASIC UNDERSTANDING OF ISSUES covered by our Code of Conduct and
Corporate Integrity Program policies. Corporate Integrity Program policies are
posted on the Intranet at http://nat1wprd2/corp_integrity/ and available from
the Corporate Integrity Program (508-650-8477).
- - HAVE A DETAILED UNDERSTANDING of corporate, regional, site, departmental, or
other policies and procedures that apply to your job.
- - UNDERSTAND THE MANY OPTIONS you have for raising integrity concerns. They are
listed on page 2 of our Code of Conduct. A chart describing these options is
included in the back of our Code. Copies of the Code are available in the
Investor Relations, Corporate Governance section of
http://www.bostonscientific.com and in the Corporate Integrity Program Intranet
site (http://nat1wprd2/corp_integrity/).
- - IMMEDIATELY RAISE ANY INTEGRITY CONCERN that you may have about business
conduct that may violate our Code of Conduct or any Boston Scientific policy, or
about a request that you believe appears to be illegal or unethical.
- - IF YOU RAISE AN INTEGRITY CONCERN and believe that it has not been timely
addressed, continue to raise it to appropriate people until it is addressed.
- - COOPERATE with Boston Scientific's investigations into integrity concerns.
- - DO NOT RETALIATE against any person because he/she makes a good faith report
of an integrity concern, or cooperates with an investigation of such concern,
including reports made to or investigated by Boston Scientific, a government or
a government official.
QUESTIONS? Speak with your manager.
GETTING ADVICE AND REPORTING INTEGRITY CONCERNS
Employees are encouraged to resolve integrity concerns locally. Sometimes it may
be more comfortable or appropriate to contact site, regional, divisional or
corporate resources to help you resolve an integrity concern. If you feel an
integrity concern is not being addressed, contact one of the Other Resources.
EMPLOYEE
YOUR SUPERVISOR
YOUR SUPERVISOR'S
MANAGER
SITE, REGIONAL, OR
DIVISIONAL MANAGEMENT
SENIOR CORPORATE
MANAGEMENT
OTHER RESOURCES
HR Representative
Legal Department Lawyer
Advise line (888-968-8425)
Functional Management
(sales, marketing, regulatory, operations, etc.)
Corporate Analysis and Control
Corporate Security
BOSTON
SCIENTIFIC